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WD-7

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of CaliforniaAmerican Water Company (U210W) for a Certificate of Public Convenience and Necessity to Construct and Operate its Monterey Water Supply Project to Resolve the Long-Term Water Supply Deficit in its Monterey District and to Recover All Present And Future Costs in connection Therewith in Rates

Application No. 12-04-019 (Filed April 23, 2013)

DIRECT TESTIMONY OF JOSEPH W. OLIVER

De LAY & LAREDO David C. Laredo, CSBN 66532 Heidi A. Quinn, CSBN 180880 Alex J. Lorca, CSBN 266444 606 Forest Avenue Pacific Grove, CA 93950-4221 Telephone: (831) 646-1502 Facsimile: (831) 646-0377 Email: dave@laredolaw.net heidi@laredolaw.net alex@laredolaw.net

Attorneys for MONTEREY PENINSULA WATER MANAGEMENT DISTRICT February 22, 2013

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of CaliforniaAmerican Water Company (U210W) for a Certificate of Public Convenience and Necessity to Construct and Operate its Monterey Water Supply Project to Resolve the Long-Term Water Supply Deficit in its Monterey District and to Recover All Present And Future Costs in connection Therewith in Rates

Application No. 12-04-019 (Filed April 23, 2013)

DIRECT TESTIMONY OF JOSEPH W. OLIVER

INTRODUCTION Please state your name, business address, and telephone number. My name is Joseph W. Oliver. My business address is 5 Harris Court, Building G, Monterey, California 93940. My telephone number is (831) 658-5640.

By whom are you employed and in what capacity? I am employed by the Monterey Peninsula Water Management District (MPWMD or Water Management District or District) as Water Resources Division Manager.

What are your responsibilities? As the manager of the Water Resources Division, I am responsible for the supervision of the Water Resources Divisions programs, services, and staff. The Water Resources Division is comprised of two functionary units, the Hydrologic unit and the Fisheries unit, with three full-time staff in each unit. Program responsibilities and services provided strategies and budgets for California American Waters (Cal-Ams) main water
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distribution system, and the annual Carmel River Memorandum of Agreement (MOA) among Cal-Am, California Department of Fish and Game (CDFG) and the Water Management District that governs reservoir releases to the lower Carmel River during the low-flow season. As the Water Resources Division manager, I prepare assignments, provide direction and help resolve issues related to the Divisions activities. In addition, I am responsible for the development and implementation of the MPWMD aquifer storage and recovery program in the Seaside Groundwater Basin. All of these activities are either in direct response to the mitigation measures described in the 1990 Water Allocation Program Environmental Impact Report (EIR), or are necessary in order to describe, evaluate and mitigate impacts to the identified environmental resources from the Water Allocation Program.

Briefly describe your education background. My education includes a bachelor's degree in geology, and master's degree in geology, specializing in hydrogeology, from Indiana University, and post-graduate training in groundwater engineering at the University of Colorado.

Please describe your professional experience. I am a registered Professional Geologist (No. 4604) and Certified Hydrogeologist (No. 164) in California, and a Certified Professional Hydrogeologist (No. 964) with the American Institute of Hydrology. My professional membership includes the National Ground Water Association and the California Groundwater Association. I have 34 years of professional experience in the field of groundwater hydrology, working for government agencies and private industry. I have been working at the Monterey Peninsula Water Management District (MPWMD or District) for over 26 years, where I have also held the positions of Geohydrologist, and Senior Hydrogeologist. During my employment with the MPWMD, I have been involved in analysis and development of the
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groundwater resources within the District, with particular emphasis on the Monterey Peninsula Water Resources System (MPWRS). The MPWRS includes the Carmel River Alluvial Aquifer and the Seaside Groundwater Basin. I have authored or co-authored numerous technical documents related to the groundwater resources of the District, and have served as project manager on most hydrogeologic investigations conducted for the District since I began employment at MPWMD. My work at the MPWMD has included planning, design and development of the Districts aquifer storage and recovery program in the Seaside Basin.

Have you previously provided testimony to the California Public Utilities Commission? Yes. I provided testimony on Cal-Ams 2010 Amended Application filed on August 26, 2011 to Application No. A.10-01-012 filed January 5, 2010 for an order authorizing the collection and remittance of the Monterey Peninsula Water Management District User Fee.

PURPOSE OF TESTIMONY What is the purpose of this direct testimony? The purpose of my testimony is to provide comment on the proposed desalination plant intake facilities of the Monterey Peninsula Water Supply Project (MPWSP) described in testimony submitted by California American Water.

Does MPWMD have any concerns regarding the plan for extracting desalination plant feed water via slant wells, as proposed in Cal-Ams application materials and testimony to the CPUC? Yes, MPWMD staff has reviewed Cal-Ams application materials and testimony and has several concerns regarding the proposed use of the shallow sand dunes aquifer rather than the180-foot aquifer, and the proposed gravity intake system, described as follows.
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Slant well extraction from the shallow dunes aquifer rather than the 180-foot aquifer. The background materials attached to Richard Svindlands 1/11/13

supplemental testimony indicate that in order to minimize impacts on the 180-aquifer, the currently proposed concept is for these wells to draw water from under the ocean floor from either the surface formation (aquifer) known as the Sand Dunes Formation or the deeper 180-foot aquifer, or from both. 1 This concept is somewhat consistent with a guest commentary by Cal-Am President Rob MacLean posted on January 11, 2013 on the Monterey County Herald website. In that posting, it is stated We have recently expressed our preference to draw from the shallow aquifer, rather than the 180-foot aquifer, which should largely satisfy the concerns of growers. However, our concern, based on groundwater exploration work in the shallow dunes aquifer nearby the proposed CEMEX property intake site, strongly suggests that the raw water intake capacity required for either the 9.6 MGD-sized desalination plant (without Groundwater Replenishment Project [GWR]) or the 6.4 MGD-sized plant (with GWR) could not be met from the dune sand aquifer via the proposed 7 to 9 slant wells to be located at this site. In 1991 and 1992, groundwater exploration work was conducted for MPWMD by the firm of Staal, Gardner & Dunne (SGD) immediately south and within the current CEMEX property 2. This report does not appear to be cited or utilized in the

supplemental testimony materials, but contains useful near-site information from which estimates of likely slant well production capacity from the shallow dune sand aquifer could be derived. For example, this study developed a range of estimates for Transmissivity of the shallow dune sand aquifer. Utilizing the highest calculated

average Transmissivity value of 99,900 gallons per day per foot (gpd/ft), the theoretical

RBF Consulting, 2013, Contingency Planning for the MPWSP (Update of November 1, 2012 TM). Memorandum prepared for California American Water, January 9, 2013 [In Attachment 9 to Richard Svindlands 1/11/13 supplemental testimony to CPUC]. See page 1. 2 Staal, Gardner & Dunne, Inc., 1992, Feasibility Study, Saline Ground Water Intake System, Monterey Sand Company Site, prepared for MPWMD, February 1992. See aquifer analysis discussion on page 8. DIRECT TESTIMONY OF JOSEPH W. OLIVER A. 12-04-019 PAGE 5

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Specific Capacity of a well completed in the dunes sand aquifer can be estimated at up to 50 gallons per minute per foot of drawdown (gpm/ft) 3. This assumes a 100% efficient well, which is not achievable in practice. Assuming a potentially obtainable well

efficiency of 75% results in a Specific Capacity of 37 gpm/ft. This value may be lower as evidenced from nearby testing conducted by Fugro West 4 for the Marina Coast Water District desalination facility feedwater well in the shallow dune sand aquifer that displayed a specific capacity of 22 gpm/ft. This near-site investigation also does not appear to be cited or utilized in the supplemental testimony materials. Slant wells may be able to be developed to be more efficient compared with vertical wells due to the greater screen length per vertical foot of penetrated aquifer, but this would need to be demonstrated in the local setting as part of the proposed slant well testing program. Limitations regarding the proposed gravity intake system. From the drawing in Figure 7 of the RBF memorandum in Attachment 11 to Richard Svindlands 1/11/13 supplemental testimony, the maximum operational drawdown via the gravity intake system would be approximately 20 feet (greater drawdown could result in cascading of water into the gravity caisson causing undesirable air entrainment). This drawing, titled Profile A-A of Southern Intake Well Cluster, is included below for convenience \\ \\ \\ \\ \\ \\ \\

Driscoll, 1986, Groundwater and Wells, 2nd Edition. See empirical equation to estimate specific capacity and transmissivity in Appendix 16D. 4 Fugro West, Inc., 1996, Summary of Operations Construction and Testing of Seawater Intake Well and Brine Injection Well, prepared for MCWD, April 1996. See discussion of constant-rate test on page 4. DIRECT TESTIMONY OF JOSEPH W. OLIVER A. 12-04-019 PAGE 6

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Using 20 feet of available drawdown results in a range in the estimated maximum yield for wells producing water from the shallow dune aquifer with the drawdown restriction of the proposed gravity feed system of 440 to 740 gallons per minute 5. This could require between 22 to 36 slant wells to meet the 23 MGD required production for the 9.6 MGDsized plant, and between 14 to 24 wells to meet the 15 MGD required for the 6.4 MGDsized plant, without consideration of any redundant well capacity. Considering the data from these nearby investigations of the dune sand aquifer raises significant questions as to whether reliance on the underlying 180-foot aquifer can be avoided or minimal in meeting the desalination plant intake needs.

Q9.

Does MPWMD have any knowledge or understanding as to whether the 180-foot aquifer is confined or unconfined in the proposed slant well project area, as related to potential groundwater impacts from project operations?

Well yield = SpC x available drawdown (ex.: 740 = 37 x 20). DIRECT TESTIMONY OF JOSEPH W. OLIVER A. 12-04-019 PAGE 7

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A9.

This issue is addressed on page 7 of Richard Svindlands 1/11/13 supplemental testimony, which states: Finally, CAW understands that there is controversy as to whether the 180-foot aquifer is a confined or unconfined aquifer, and the attendant effects of MPWSP pumping in light of those conditions. As of yet, CAW has not had an independent hydrogeologist evaluate those claims and has not decided if it will hire its own expert. CAW understands that the Commission may address that controversy in its EIR. CAW has reason to believe, however, that reports claiming the 180-foot aquifer is a fully confined aquifer are based on outdated information. MPWMD concurs that based on available information there are indications that a thick sequence of low-permeability aquitard materials may not exist above the 180-foot aquifer sediments in the proposed slant well project area that could provide a fully-confined condition such as exists farther northeastward in the Salinas Valley Groundwater Basin. However, review of the

geophysical logs and cross section from the groundwater exploration investigation 6 conducted for MPWMD immediately south and within the CEMEX property indicates a continuous, thin (+/- 10 feet) clay layer below the dune sand deposits at approximately 40 to 50 feet below mean sea level. If this unit is laterally continuous outside the area investigated, it could provide some degree of confinement within the underlying 180-foot aquifer. In addition, although the focus of this investigation was the shallow dune sand aquifer and not on deeper hydrostratigraphy, three deeper test holes were drilled that penetrated through the dune sands and into the underlying deposits, described as alluvium in the report. These test holes extended to elevations about 240 feet below mean sea level, which would approximate the elevation of the maximum expected length of the continuous over a broad enough area. Accordingly, additional understanding of the

Staal, Gardner & Dunne, Inc., 1992, Feasibility Study, Saline Ground Water Intake System, Monterey Sand Company Site, prepared for MPWMD, February 1992. See Plate 1 and Appendix B. DIRECT TESTIMONY OF JOSEPH W. OLIVER A. 12-04-019 PAGE 8

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proposed slant wells of 630 lineal feet 7. Review of the lithologic logs for these test holes indicates the presence of several zones of high clay content that could also provide some degree of confinement if these zones are laterally continuous over a broad enough area. Accordingly, additional understanding of the occurrence and continuity of such lowpermeability zones in the vicinity of the proposed slant wells should be further considered as part of the proposed slant well testing program.

Does this conclude your testimony?

A10. Yes.

RBF Consulting, 2013. Monterey Peninsula Water Supply Project (MPWSP) Project Description Update. Memorandum prepared for California American Water, January 9, 2013 [In Attachment 11 to Richard Svindlands 1/11/13 supplemental testimony to CPUC]. See page 6 under Slant Wells. DIRECT TESTIMONY OF JOSEPH W. OLIVER A. 12-04-019 PAGE 9